- Lifesaving & Fire Safety

New Policy Letter: Equivalency Determination – Fire pumps for Subchapter C and Subchapter M towing vessels

The Office of Design and Engineering Standards published Policy Letter 01-19: “Equivalency Determination – Fire Pumps for Subchapter C and Subchapter M Towing Vessels” to provide guidance on the use of fixed fire pumps in lieu of portable fire pumps on vessels 65 feet or less.

When developing the 2003 interim rule and 2004 final rule addressing fire-suppression systems and voyage planning for towing vessels, the Coast Guard assumed smaller vessels would utilize portable fire pumps, while larger vessels would utilize fixed fire pumps; therefore, vessel size was not associated with fire pump requirements. This assumption imposed a larger burden on smaller vessels that opted to install fixed fire pumps. Generally, the fixed pump is required to have a higher capacity to accommodate the greater hydraulic losses expected from the extensive fire main systems used in larger vessels. In small vessels, however, the hydraulic losses of the smaller fire main systems are negligible, and the fixed fire pump need be of no higher capacity than the portable pump. Thus, in small vessels, fixed and portable pumps of similar capacity will provide similar fire streams affording an equivalent level of safety.

Accordingly, for towing vessels 65 feet or less subject to 46 CFR 27.301 or 46 CFR 142.325, vessels may use a fixed fire pump that meets the performance requirements of the portable fire pump in 46 CFR 27.301e(1) or 46 CFR 142.325e(1) in lieu of the requirements in 46 CFR 27.301a(1) or 46 CFR 142.325a(1).

For more details, view the entire policy letter. Please contact the Coast Guard’s Lifesaving and Fire Safety Division (CG-ENG-4) at typeapproval@uscg.mil with any questions on the material.

This blog is not a replacement or substitute for the formal posting of regulations and updates or existing processes for receiving formal feedback of the same. Links provided on this blog will direct the reader to official source documents, such as the Federal Register, Homeport and the Code of Federal Regulations. These documents remain the official source for regulatory information published by the Coast Guard.